Taxation of entertainers and athletes: source state may tax performance income, subject to public funding exceptions limiting source taxation. Income of entertainers and athletes from personal activities exercised in the other Contracting State is taxable in the State where the activities are performed; if such income accrues to another person it may also be taxed in the source State. Exceptions: if the entertainer or athlete is supported wholly or substantially from the public funds of his residence State, taxation is limited to the residence State; if the recipient other than the entertainer is supported wholly or substantially from the public funds of the source State, taxation is limited to that source State.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Taxation of entertainers and athletes: source state may tax performance income, subject to public funding exceptions limiting source taxation.
Income of entertainers and athletes from personal activities exercised in the other Contracting State is taxable in the State where the activities are performed; if such income accrues to another person it may also be taxed in the source State. Exceptions: if the entertainer or athlete is supported wholly or substantially from the public funds of his residence State, taxation is limited to the residence State; if the recipient other than the entertainer is supported wholly or substantially from the public funds of the source State, taxation is limited to that source State.
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